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FIRST AMERICAN NAT. BANK OF NASHVILLE v. UNITED STATES

No. 71-1491.

467 F.2d 1098 (1972)

FIRST AMERICAN NATIONAL BANK OF NASHVILLE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

October 4, 1972.

Attorney(s) appearing for the Case

William Waller, Nashville, Tenn., for plaintiff-appellant; Waller, Lansden, Dortch & Davis, Nashville, Tenn., on brief.

Virginia M. Hopkinson, Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee; Charles H. Anderson, U. S. Atty., Nashville, Tenn., Johnny M. Walters, Asst. Atty. Gen., Fred B. Ugast, Meyer Rothwacks, Grant W. Wiprud, Attys., Tax Div., Dept. of Justice, Washington, D. C., on briefs.

Before McCREE and KENT, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.

PER CURIAM.

This is an appeal from the district court's denial of plaintiff's action to recover income taxes paid on certain interest income for the years 1961, 1962, and 1963. A number of other issues were decided, but no appeal has been taken from the district court's disposition of them. The case was submitted on the pleadings and a stipulation of facts.

Plaintiff bank, a licensed bond dealer, instituted this action to recover taxes paid on interest it...

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